Law360’s Zachary Zagger has a nice piece on the FIFA prosecution and quotes, among others, Jack Sharman: “Given this many defendants and the fact that there is going to be at least some who are going to cooperate, it would not surprise me if there wasn’t a second wave of charges or people coming out of the woodwork, people you have not heard of yet,” said Jackson R. Sharman III, a white collar criminal defense attorney with Lightfoot Franklin & White LLC. “If it is going to survive, it is going to have to have a more rigorous compliance structure than some of the items that have come across thus far,”…

Except perhaps for “paradigm” and “silo,” the word “culture” is one of the most abused in the vocabulary of compliance, ethics and consultants. (I once heard a consultant say that he needed “a high hover over the silos.” I thought it an ironic mash-up about drones and agriculture; it was not). Yet, “culture” has a meaning in the broader world; in commerce; and in compliance. “Culture” represents a gear-shift in compliance and ethics, and can be smooth or bone-rattling. Consider this story about McKinsey’s culture in the wake of insider-trading scandals: For a quarter of a century, except for a brief stint as a currency analyst at Rothschild, Mr. Barton has…